Legal · v1 Draft

Privacy Policy.

EFFECTIVE DATE · TBD · PENDING LAWYER REVIEW
⚠ DRAFT — pending lawyer review This document is a working placeholder. Final language is being prepared with our Australian financial-services counsel (Sophie Grace / equivalent). Do not rely on this as final policy until an "Effective Date" replaces "TBD" above. If you have urgent questions in the interim, contact peter@kritsotakis.com.au.

1. Who we are

EXIT CODE is a trading discipline tool operated by Kritsotakis Investments Pty Ltd (ACN 153 844 136) as trustee for the Kritsotakis Family Trust (ABN 45 984 876 899), an Australian discretionary trading trust registered in NSW. References to "we", "us", "our", or "EXIT CODE" mean Kritsotakis Investments Pty Ltd in its capacity as trustee for the Kritsotakis Family Trust.

We are not a broker. We do not execute trades. We do not provide financial advice. See our Terms of Service for the full description of what EXIT CODE does and does not do.

2. What information we collect

Information you provide directly

Information collected automatically

Information we do NOT collect

3. How we use your information

4. Who we share your information with

We share data only with the third-party services we depend on to operate the business:

We do not sell your data. We do not share it for marketing purposes.

5. Data retention

Account active: data is retained as long as your subscription is active.

Account cancelled: trade journal data is retained read-only for 30 days, then archived (not deleted — kept for your potential resubscription) for 12 months, then permanently deleted.

Email addresses are retained until you unsubscribe or request deletion.

6. Your rights

To exercise any of these rights, email privacy@exitcode.trade (forwarder TBD — currently routes to peter@kritsotakis.com.au).

7. Security

We use industry-standard encryption (TLS 1.3 in transit, AES-256 at rest). Payment data never touches our servers — Stripe handles all card processing. Account credentials are stored as bcrypt hashes.

We have no realistic way to be more secure than the underlying providers we use (Stripe, Supabase, Vercel). If you are concerned about a specific threat model, contact us before subscribing.

8. International transfers

If you are in the EU, UK, or California, your data may be transferred to and processed in Australia or the United States (via our US-based service providers). We rely on Standard Contractual Clauses (EU) and equivalent transfer mechanisms.

9. Children

EXIT CODE is not for users under 18. We do not knowingly collect data from children.

10. Changes to this policy

If we make material changes, we will email registered users with at least 30 days' notice before the change takes effect.

11. Contact

Privacy concerns: privacy@exitcode.trade
Australian Privacy Commissioner (if you wish to complain): oaic.gov.au